The British Sandwich and Food to Go Association has published it's response to the Scottish Government’s ‘A Healthier Future’ Consultation.

This response covers three key sectors of the UK foodservice economy,– estimated to be worth around £7 billion (source Allegra Strategies).

This response covers the views of three trade associations, The Sandwich and Food to Go Association, The Pizza, Pasta and Italian Foods and The Café Life Association which, together, represent the interests of over 2000 businesses across the UK, some of which operate in Scotland. These businesses range in size from very large to small family run cafes and sandwich bars.

Our organisations are fully supportive of the need to tackle the obesity problems in Scotland and, indeed, across the UK. We take the view that this is best tackled by co-operation between Government and businesses with the understanding that change in consumer diets needs to be a co-operative effort over time and the imposition of quick solutions can backfire if consumers feel that their right to choice is being denied.

Over the last few years our organisations have been working with the UK Government to reduce salt and fat in products which has resulted in significant changes in the formulation of products. For example, the targets set for the pizza retail sector have been largely achieved and in many cases exceeded through co-operation. However, this has been a managed process taking account of consumer reactions. Indeed, there have been examples of consumers rejecting products as too bland because reductions have been made too fast which underlines the need for care in structuring programmes.

In the case of salt reduction, there is some evidence that some consumers are adding back salt into ready-made products which can completely negate the work that has been done.

Q1: Are there any other types of price promotion that should be considered in addition to those listed above?

While we understand the motivation for controlling price promotions, they are not necessarily always designed to sell more product. Promotions can be used to encourage changes in consumer behaviour, such as to buy healthier options, and can also play a significant part in minimising waste by incentivising sales of products as they approach the end of their shelf-life.

We would encourage the Scottish Government to work closely with retailers and manufacturers in constructing guidelines on promotions that achieve the desired results without creating issues elsewhere in the supply chain.

It is difficult to comment further without more detail about the plans to control promotions.

Q2: How do we most efficiently and effectively define the types of food and drink that we will target with these measures?

Not all consumers are obese and they can have very different dietary needs. We believe that long term change will be driven by consumers and that the most important aspect of this is for businesses to provide the information they need to make healthy choices.

Indeed, we are already seeing ‘health’ becoming a major driver in terms of the products consumers are buying and this, in turn, will further drive change in the supply of foods at all levels in the market.

The critical factors are less about the foods themselves than the importance of providing accurate nutritional information and educating consumers about healthy eating.

The introduction of pack nutritional information has been a major step forward in the packaged food industry and has been picked up in different ways by the bigger businesses in the foodservice sector. However, there is still a long way to go as the bulk of smaller foodservice outlets need help in this area as few have access – or can afford – the technical know-how to provide the correct information. Many are also fearful that if they get it wrong they may fall fowl of Trading Standards.

Rather than castigate specific foods, we believe more could be done to make sure consumers have the information they need to make the right choices.

Education and media support for healthy eating also have a major role to play both in the short and long term.

Q3: To what extent do you agree with the actions we propose on non-broadcast advertising of products high in fat, salt and sugar?

We do not believe that a blanket ban is necessary as it could be unfairly damaging for some sectors of the industry and some products that are not necessarily unhealthy. Vegetarian pizzas, for example, can be relatively low in calories as are some burgers. Indeed, there is an argument that healthier versions of some products should be promoted more strongly.

Q4: Do you think any further or different action is required for the out of home sector?

We believe that clear labelling and consumer education are the keys to tackling the obesity problem in the long term. To this end we fully support calorie labelling and portion guidance but we have major concerns about caps on calories or portions.

In terms of calories, help needs to be given to smaller businesses in providing reliable nutritional information on products as most do not have access to the technical know-how to provide this. It is also costly for them to obtain the right information as testing is expensive.

At the same time better advice is needed on what a standard portion size should look like so that there is more consistency in approach.

There are also technical issues with reducing calorie levels in products that need to be taken into consideration as reformulations to achieve one goal can create new problems. For instance, shelf-life can be affected which can drive up food wastage.

Reductions in portion sizes can also have negative consequences. For example, there is unlikely to be any significant reduction in product prices as the main costs of making products are in the manpower and other overheads rather than the ingredients. There have been examples in the past of consumers baulking at reductions in portions because the costs have remained the same.

Furthermore, if consumers feel that recommended portions are too small they may be driven to buying ‘extras’ or to more snacking between meals, thus defeating the objective.

It is important that any proposed changes are undertaken in consultation with food technologists in the commercial sector to ensure their viability.

We must also remember that the main competitor of the food-to-go commercial market is the made-at-home market over which far less control can be exercised.

Our view is that changes need to be managed by Government and food businesses in co-operation if long term success is to be achieved.

Q5: Do you think the current labelling arrangements could be strengthened?

As stated above, we believe that front-of-pack labelling is one of the keys to getting long term change in consumer eating habits but it needs to be extended across the entire food sector, including smaller foodservice businesses. In order for this to happen assistance needs to be given to SME’s to provide this information without fear of getting it wrong and misleading.

We have urged the UK Department of Health in the past to provide on-line calculators as well as simple to follow guidance to help small businesses provide this information. This would be a useful investment by the Scottish Government.

Q6: What specific support do Scottish food and drink SME’s need most to reformulate and innovate to make their products healthier?

SME’s do not generally have the technical knowledge to reformulate products or provide the correct information for consumers on nutrition. They also lack the financial resources to rely on testing.

We would suggest that the best way for the Scottish Government to spend the £67,000 it is planning on support for SME’s would be to focus this on providing the means for these businesses to provide more consumer information.

Q7: Do you think any further or different action is required to support a healthy weight from birth to adulthood?

We fully support the Scottish Government’s proposal to invest in making food and nutrition a greater part of the school curriculum as well as the focus on physical exercise.

Q11: What do you think about action we propose for making obesity a priority for everyone?

We fully support the importance for increasing awareness about obesity with all sectors of the public as well as encouraging people to be more focused in managing their diets.

While obesity is not entirely a food issue – changes in lifestyles being a major contributor – there is undoubtedly a need for consumers to be more aware of managing their food intake and the provision of clear and concise nutritional information on all foods is important to achieving this.

Q14: Do you have any other comments about any of the issues raised in this consultation?

We would urge the Scottish Government to take full account of the economic impact on businesses and employment in implementing changes in this area. The UK food industry makes a substantial contribution to the economy and will need time to implement changes.

We are also mindful of the nature of many businesses which trade across borders where substantive changes in product formulations can have considerable impact on the practicalities of supplying markets.

In addition to the Scottish Government proposals, Public Health England is also looking at nutrition and diet in relation to portions and calories. Salt and fat targets are also due to be reviewed by the British Government in the next year.

It would be helpful to have a cohesive approach in these areas across borders.